Pension IHT from 6 April 2027 — What to Do Before the Change

On 6 April 2027, the long-standing treatment of unused defined-contribution (DC) pension funds as outside the estate for Inheritance Tax ends. From that date, most unused pension pots — and discretionary pension death benefits — form part of the deceased’s estate, with personal representatives (not scheme administrators) liable for the IHT charge.

You have until 6 April 2027 to decide whether to act, and what to act on. The right strategy depends heavily on the size of your estate and who you intend to benefit. This article breaks the decision into four persona segments.

The Change in One Paragraph

From 6 April 2027, unused DC pension funds at death — plus most discretionary death benefits paid under pension scheme rules — are added to the estate’s taxable value. The standard £325,000 nil-rate band and £175,000 residence nil-rate band (the residence nil-rate band tapers away for estates above £2M) still apply. The 40% standard rate applies above allowances; 36% if ≥10% of the net chargeable estate passes to charity. Spouse, civil partner and charity exemptions still apply, and death-in-service benefits and dependants’ scheme pensions from defined benefit or collective money purchase schemes are excluded from the new rule.

Persona 1: Total estate under £325,000 — No action needed

If your total estate (pension + property + savings + investments + life cover payouts outside trust) comes in at or below the £325,000 nil-rate band, the change does not affect your IHT position — 100% of the estate is covered by the nil-rate band regardless of whether the pension is “in” or “out”. Using the planner to confirm the calculation is sensible; changing the pension arrangement is not.

Persona 2: £325,000–£1,000,000 with a surviving spouse — Defer via spouse-first planning

Pension funds left to a spouse or civil partner stay outside the estate (full spousal exemption), so the 2027 rule only bites on the second death. The most efficient route for this bracket:

1. Leave the pension to your spouse — or nominate them as beneficiary of any discretionary death benefits.
2. Remember unused NRB and RNRB transfer to the surviving spouse or civil partner, so little allowance is lost by leaving assets to them on the first death.
3. Phased drawdown after age 55/57 only if you need the income, not to “beat the deadline” — the income tax cost usually outweighs any IHT benefit at this estate size.
4. Don’t triple-nominate or over-index on gifting. On the second death, transferable NRB + RNRB typically absorb most of the combined estate anyway.

Persona 3: £1,000,000–£2,000,000 — Combination play (gifting + drawdown + ISA wrapping)

This is the bracket where the 2027 change bites hardest — RNRB is largely intact (taper hasn’t started), but the pension suddenly becomes a taxed asset. The playbook:

1. Start a phased drawdown strategy well before death — £10k/year above MPAA is inconsequential, but £40k–£60k/year over 10+ years meaningfully reduces the pot.
2. Gift the drawn proceeds rather than spending them: the 7-year clock starts immediately, and the gift falls fully outside the estate if you survive seven years from the date of gift. Income tax is paid on the drawdown at your marginal rate — typically 20%–40%.
3. ISA wrapping after drawdown: if you prefer not to gift, move the post-tax drawdown into an ISA. ISA balances are still estate-assessable, but you can manage withdrawals strategically, and an ISA holding AIM shares can qualify for Business Property Relief (though only at 50% since 6 April 2026).
4. Revisit the nomination form and ask your scheme what dependant routes it offers. Finance Act 2026 s66(6) excludes dependants’ scheme pensions, and a dependants’ or nominees’ annuity only where it was purchased together with a lifetime annuity payable to the member, so a dependant’s annuity arranged only after death from a defined contribution pot is not excluded.

Persona 4: Over £2,000,000 (RNRB taper zone) — Aggressive restructuring

Above £2M, the residence nil-rate band tapers away (£1 for every £2 above the threshold), so an estate of £2.35M or higher loses RNRB entirely. Combined with the 2027 pension change, high-net-worth estates face a meaningful step-up in effective IHT rates. Priority actions:

1. Annuitise a portion of the pension pot yourself with a single-life annuity and no guarantee period — nothing is left to form part of the estate when you die, though you give up the capital and flexibility.
2. Business Property Relief (BPR) / Agricultural Property Relief (APR) for qualifying business assets, now capped at £2.5M per person (combined) with 50% relief above. Couples can shelter up to £5M combined. This is a separate but closely related planning lever after the 2026 BPR/APR reform — see our BPR & APR calculator.
3. Charity 10% threshold — leaving ≥10% of the net chargeable estate to a registered charity reduces the IHT rate from 40% to 36% on the entire chargeable estate. For estates well over the £2M threshold, this can meaningfully outperform the alternative.
4. Dependant’s scheme pension election where the scheme permits — dependants’ scheme pensions are an excluded benefit under Finance Act 2026 s66(6), so they are left out of the 2027 estate calculation.
5. Consider gift-splitting with a spouse to maximise the combined 7-year runway.

Timing and Mechanics

Before 6 April 2027:

• Any drawdown + gift cycle started now starts the 7-year clock before the rule changes.
• Nominations can be refreshed; scheme administrators should provide an up-to-date form.
• If you’re close to age 55 (now 57 from 2028), ensure you understand how crystallising the pension interacts with the MPAA and your future contribution plans.

After 6 April 2027:

• Personal representatives must report pension funds on IHT400 alongside other estate assets; HMRC will publish the revised form and reporting guidance before the effective date.
• Any gift made before 6 April 2027 that pre-crystallises value out of the pension is preserved — the gift is judged by the date of gift, not the date of death.

What Not to Do

• Don’t panic-drawdown at 45% marginal rate. Paying 45% income tax to avoid 40% IHT is net-negative in most cases, especially when the gifted proceeds could still attract taper IHT if you don’t survive seven years.
• Don’t trigger MPAA unnecessarily. If you still want to contribute to pensions (yourself or via a spouse), taking drawdown income or an UFPLS now caps your future money purchase Annual Allowance at £10,000 (taking only the tax-free cash does not).
• Don’t assume scheme rules won’t change. Some schemes may revise discretionary trust provisions or permit alternative death-benefit routing in response to the rule — keep in touch with your scheme administrator before locking in a strategy.

Next Steps

• Run your numbers through the Pension IHT 2027 Planner to see the post-2027 regime versus your chosen strategy.
• Cross-check with the Inheritance Tax Calculator for your full estate picture including NRB and RNRB interactions.
• If you hold business or agricultural assets, the BPR & APR Calculator models the separate £2.5M combined cap that took effect 6 April 2026.
• Scheme-specific nominations, dependant-annuity routing, and discretionary trust variations should be confirmed with a STEP-qualified solicitor or chartered tax adviser before acting.